COMPLIANCE CALENDAR: Your Year-Round Legal Checklist.

COMPLIANCE CALENDAR: YOUR YEAR-ROUND LEGAL CHECKLIST

A Regulatory Filing Guide for Start-ups, Established Companies and Non-Profits

1.  Why This Calendar Exists

Compliance in Nigeria is not a single event but a rhythm. Obligations fall due monthly, quarterly and annually across at least a dozen regulators, and the cost of missing a date is rarely limited to the penalty itself: an inactive status at the Corporate Affairs Commission can stall a financing round, a lapsed data protection filing can derail a due diligence exercise, and accumulated defaults become personal liabilities for directors. Since 1 January 2024, the CAC has applied penalties for unfiled annual returns against companies and their directors and officers personally, and prolonged default remains a ground for striking a company off the register.

The calendar below reflects the law as it stands in July 2026, including three developments that have quietly rendered many circulating compliance calendars obsolete: the consolidation of the NITDA, tertiary education, NASENI and Police Trust Fund levies into a single 4% Development Levy under the Nigeria Tax Act 2025; the recalibration of data protection audit deadlines under the NDPC’s General Application and Implementation Directive (GAID) 2025; and the Corporate Affairs Commission’s enforcement posture on the 30 June annual returns window.

2.  Corrections to Commonly Circulated Calendars

Before setting out the calendar itself, it is worth flagging the errors we most frequently encounter in compliance calendars in circulation, because a confidently wrong date is more dangerous than no date at all.

Item as commonly (and incorrectly) calendared	The correct position	Authority
CAC annual returns	Business names file on or before 30 June each year; companies file within 42 days of the AGM — in practice 30 June for a 31 December year-end; incorporated trustees file between 30 June and 31 December with audited accounts. First returns fall due 18 months after incorporation.	CAMA 2020, ss 417–425, 822, 848
NDPC audit report due date	GAID 2025 moved the Compliance Audit Returns deadline from 15 March to 31 March each year. For the 2026 cycle only, the NDPC extended filing to 30 May 2026. Late filing attracts a 50% surcharge on the applicable fee.	NDPA 2023; GAID 2025, art 10; NDPC notice (2026)
NITDA levy of 1% of profit before tax as a standalone filing	From 1 January 2026, the NITDA levy (with TET, NASENI and Police Trust Fund levies) is consolidated into a single 4% Development Levy on assessable profits, filed with companies income tax returns. Small companies are exempt.	Nigeria Tax Act 2025, s 59
PAYE remittance due 31 January	Monthly PAYE is due by the 10th day of the month following payment of salaries. 31 January is the deadline for the annual employer return (Form H1) covering the preceding year.	PITA (as amended); state tax administration laws
ITF audit in August	The annual ITF contribution of 1% of the preceding year’s payroll is due by 1 April. Reimbursement claims and audits follow contribution, not the reverse.	ITF Act (as amended)
WHT reconciliation as a single annual event	WHT must be remitted monthly — within 21 days of the month of deduction for federal taxes. A year-end reconciliation is good practice, not the statutory remittance obligation.	Deduction of Tax at Source (WHT) Regulations 2024
AGM minutes filed with CAC in December	There is no general obligation to file AGM minutes. Small companies and single-member companies are exempt from holding AGMs altogether; what must be filed is the annual return with accompanying documents.	CAMA 2020, s 237

3.  The Master Calendar — All Entities.

Abbreviations: CAC — Corporate Affairs Commission; NRS — Nigeria Revenue Service (successor to the FIRS from 2026); SIRS — State Internal Revenue Service (LIRS in Lagos); NDPC — Nigeria Data Protection Commission; NCC — Nigerian Communications Commission; PenCom — National Pension Commission; ITF — Industrial Training Fund; NSITF — Nigeria Social Insurance Trust Fund; SON — Standards Organisation of Nigeria; SCUML — Special Control Unit Against Money Laundering.

Due date	Regulator	Compliance obligation	Cycle	Applies to
Q1
10th of each month	SIRS (e.g. LIRS) / NRS	PAYE remittance for the preceding month	Monthly	All employers
21st of each month	NRS	VAT returns and remittance; WHT (federal) within 21 days of the month of deduction	Monthly	All VAT-registered entities
Within 7 working days of salary payment	PenCom	Remittance of pension contributions (18% combined) to employees’ RSAs	Monthly	Employers with 3 or more employees
31 Jan	SIRS (e.g. LIRS)	Annual employer PAYE returns (Form H1) for the preceding year	Annual	All employers
1 Mar	NCC	Annual Ownership Report (shareholding and directorship details)	Annual	NCC licensees (see note on 31 March filings)
31 Mar	NDPC	Compliance Audit Returns (CAR) under the NDPA and GAID 2025 — extended to 30 May 2026 for the 2025 audit year	Annual	Data controllers / processors of major importance
31 Mar	NRS	Personal income tax self-assessment returns (individuals, partners, sole proprietors)	Annual	Individuals and unincorporated businesses
Q2
1 Apr	ITF	Annual training contribution — 1% of preceding year’s payroll	Annual	Employers with 5+ employees or ₦50m+ turnover
30 May	NDPC	Extended 2026 deadline for filing 2025 Compliance Audit Returns (one-off extension from 31 March)	One-off (2026)	DCPMIs / DPPMIs
30 Jun	CAC	Annual returns — business names; companies with a 31 December year-end (within 42 days of AGM); opening of the filing window for incorporated trustees	Annual	All registered entities
30 Jun	NRS	Companies income tax returns and 4% Development Levy (consolidating the former NITDA, TET, NASENI and PTF levies) — within 6 months of financial year-end	Annual	All companies (small companies exempt from the levy)
30 Jun	NCC	Audited financial statements — within 180 days of financial year-end; AOL payable within 30 days of submission	Annual	NCC licensees
Q3
10 Jul	PenCom	Half-year pension remittance reconciliation and compliance certificate renewal preparations	Semi-annual	Employers bidding for public contracts
July Q3	NDPC	Semi-annual internal Data Protection Officer report to management (GAID)	Semi-annual	DCPMIs / DPPMIs
30 Sep	NRS / SIRS	WHT reconciliation and credit-note verification ahead of year-end	Good practice	All companies
Q4
31 Oct	SON	Product certification renewals (MANCAP / SONCAP) as applicable	Annual	Manufacturers and importers of regulated products
Monthly (by month end)	NSITF	Employee Compensation Scheme — 1% of monthly payroll	Monthly	All employers
31 Dec	CAC	Close of annual returns filing window for incorporated trustees (audited accounts attached)	Annual	NGOs, foundations, associations, religious bodies
31 Dec	SCUML	Ensure SCUML registration and transaction reporting remain current	Ongoing	Designated non-financial businesses, incl. NGOs and law firms

4.  Start-ups and Early-Stage Companies

A newly incorporated company enjoys a short statutory honeymoon, but the clock starts at incorporation. The obligations below are the ones start-ups most often discover late.

• First CAC annual return — The first annual return falls due 18 months after incorporation; no return is filed for the year of incorporation itself. Diarise the 18-month date at incorporation, not when the reminder letter arrives.
• Tax registration and first return — Register for taxes with the NRS immediately after incorporation and file the first CIT return within 18 months of incorporation or 6 months after the first accounting year-end, whichever is earlier.
• Small company reliefs — Small companies — broadly, turnover not exceeding ₦100 million and fixed assets not exceeding ₦250 million — enjoy a 0% companies income tax rate and are exempt from the 4% Development Levy, but exemption from payment is not exemption from filing. Returns must still be filed to preserve the status.
• Data protection from day one — Any entity processing the personal data of more than 200 data subjects within six months is presumptively a data controller or processor of major importance and must register with the NDPC, appoint a Data Protection Officer, and enter the annual Compliance Audit Returns cycle. Most consumer-facing start-ups cross this threshold within months of launch.
• Employment-linked filings — PAYE, pension (3+ employees), NSITF (all employers) and ITF (5+ employees or ₦50m turnover) obligations attach as soon as staff are hired — including for founders on payroll.
• Licensed activities — Fintech, healthtech, lending and communications businesses require sector licences (CBN, NCC and others) whose conditions impose their own reporting calendars in addition to everything above.

5.  Established Companies

For companies past their start-up years, the compliance burden shifts from registration to reporting discipline. The critical cluster is the mid-year window: for a 31 December year-end, the AGM, the CAC annual return, the audited financial statements, the CIT return and the Development Levy all converge on 30 June.

• AGM and annual return — Hold the AGM within the statutory timeline and file the annual return within 42 days of it. Small companies and single-member companies are exempt from holding AGMs but not from filing annual returns.
• CIT and Development Levy — File CIT returns and pay the 4% Development Levy within six months of the financial year-end. From 2026 the levy is assessed and filed alongside CIT through the NRS — treat it as one filing event, not four.
• Beneficial ownership — Maintain the register of persons with significant control and update beneficial ownership information at the CAC as changes occur, and in any event at each annual return.
• NDPC audit cycle — Where classified as a data controller or processor of major importance, complete the annual data protection audit and file Compliance Audit Returns by 31 March each year (30 May for the 2026 cycle) — through a licensed DPCO if classified ultra-high or extra-high level.
• Monthly remittances — Monthly VAT (21st), PAYE (10th), WHT (within 21 days of the month of deduction) and pension (7 working days of salary payment) remittances continue year-round; these produce the bulk of penalty exposure because they recur twelve times a year.

6.  Non-Profits and Incorporated Trustees

Associations, foundations, NGOs and religious bodies registered as incorporated trustees are subject to a distinct calendar that is routinely overlooked.

• CAC annual returns — Annual returns are filed between 30 June and 31 December each year, and must attach audited accounts showing the association’s assets, liabilities, trustees and any changes to the constitution. The audited-accounts requirement is the most common reason filings are queried.
• SCUML — Non-profits are designated non-financial institutions for anti-money-laundering purposes and must register with SCUML and maintain transaction reporting; banks will not open or sustain accounts without evidence of registration.
• Tax treatment — Income tax exemption for non-profits attaches to the organisation’s charitable activities, not to the entity absolutely: profits from business ventures are taxable, and PAYE, pension and other employment obligations apply to staff in full.
• Data protection — Non-profits that process personal data of beneficiaries, donors or members above the 200-subject threshold fall within the NDPC registration and audit regime like any company.

7.  Sector Notes — NDPC, NITDA and NCC

7.1  Data protection (NDPA 2023 and GAID 2025)

The GAID 2025, effective 19 September 2025, replaced the NDPR as the operative implementation instrument under the Nigeria Data Protection Act 2023. Data controllers and processors of major importance must file Compliance Audit Returns on or before 31 March each year (entities established after 12 June 2023 file their first return within 15 months of establishment and annually thereafter). Ultra-high and extra-high level entities must file through a licensed Data Protection Compliance Organisation. Filing fees are tiered from ₦100,000 to ₦1,000,000 by classification and data volume; late filing attracts an administrative surcharge of 50% of the applicable fee, and non-filing exposes the entity to a penalty of up to the greater of ₦10 million or 2% of annual gross revenue. For the 2026 cycle, the NDPC extended the filing deadline for 2025 returns from 31 March to 30 May 2026 — a one-off extension that should not be assumed to recur.

7.2  NITDA

The standalone 1% NITDA levy on profit before tax ceased to apply to profits assessed from 1 January 2026: it is subsumed, together with the tertiary education, NASENI and Police Trust Fund levies, into the single 4% Development Levy under section 59 of the Nigeria Tax Act 2025, filed with companies income tax returns and shared among beneficiary agencies including NITDA. Compliance calendars that still carry a separate NITDA levy line for 2026 are out of date. NITDA’s regulatory activity now bears on businesses principally through instruments such as its online harms and platform accountability framework — obligations that are conduct-based rather than date-based, and should be addressed through policy and product review rather than a filing diary.

7.3  NCC licensees

Communications licensees carry three recurring obligations beyond the general corporate calendar: an Annual Ownership Report setting out shareholding and directorship details, filed each year in the first quarter; audited financial statements submitted to the Commission within 180 days of the financial year-end; and the Annual Operating Levy, assessed on net revenue and payable within 30 days of submission of the audited accounts. Non-operational licensees remain liable for the AOL, and default attracts substantial fixed and daily penalties as well as jeopardy to licence renewal, for which applications must be made at least six months before expiry. Changes in shareholding above 10% require the Commission’s prior approval.

8.  Practical Notes

• Where a deadline falls on a weekend or public holiday, file on the last preceding working day; regulators’ portals do not reliably extend grace.
• Keep filing acknowledgements for every submission. In our experience, proof of filing resolves more regulator disputes than legal argument does.
• Companies with non-December year-ends must translate every ‘within six months of year-end’ and ’42 days of AGM’ item to their own dates; the 30 June cluster in this calendar assumes a 31 December year-end.
• Fee schedules (CAC, NDPC, NCC) are revised periodically; confirm the current figure on the regulator’s portal before payment.

Sources and Notes

1.  Companies and Allied Matters Act 2020, ss 237, 417–425, 822 and 848; Companies Regulations 2021 (penalty regime applied by the CAC from 1 January 2024).

2.  Corporate Affairs Commission, annual returns guidance: business names on or before 30 June each year; companies within 42 days of the AGM; incorporated trustees between 30 June and 31 December with audited accounts; first returns 18 months after incorporation.

3.  Nigeria Data Protection Act 2023; NDPC, General Application and Implementation Directive 2025 (issued 20 March 2025; effective 19 September 2025), art 10 and sch 2 and 10.

4.  NDPC, notice extending the 2025 Compliance Audit Returns filing deadline from 31 March to 30 May 2026.

5.  Nigeria Tax Act 2025, s 59 (4% Development Levy, effective 1 January 2026, consolidating the NITDA, TET, NASENI and Police Trust Fund levies); Nigeria Revenue Service (Establishment) Act 2025.

6.  Nigerian Communications Act 2003, ss 43, 64–66 and 70; Annual Operating Levy Regulations (as amended): audited financial statements within 180 days of year-end; AOL payable within 30 days of submission; Annual Ownership Report filed annually.

7.  Personal Income Tax Act (as amended); Pension Reform Act 2014; Industrial Training Fund Act (as amended); Employee’s Compensation Act 2010; Deduction of Tax at Source (Withholding) Regulations 2024; Money Laundering (Prevention and Prohibition) Act 2022 (SCUML designation).

Written by Adeola Osifeko, LLB, BL, LLM, ACIS ABR — Founding Partner   |  adeola@aeolawpractice.com

Disclaimer: This calendar is provided for general information only and does not constitute legal advice. Deadlines stated assume a 31 December financial year-end unless otherwise indicated, and regulatory fees and dates are subject to change. Specific advice should be sought on your organisation’s circumstances before acting. AEO Law Practice accepts no liability for reliance on this publication without engagement.

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